Internal Revenue Bulletin:
2004-5

February 2, 2004

Definition of Terms

Amplified describes a situation where no change is being made in a prior published position, but the prior position is being extended
to apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling held that a principle applied
to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare with modified, below).

Clarified is used in those instances where the language in a prior ruling is being made clear because the language has caused, or may
cause, some confusion. It is not used where a position in a prior ruling is being changed.

Distinguished describes a situation where a ruling mentions a previously published ruling and points out an essential difference between
them.

Modified is used where the substance of a previously published position is being changed. Thus, if a prior ruling held that a principle
applied to A but not to B, and the new ruling holds that it applies to both A and B, the prior ruling is modified because
it corrects a published position. (Compare with amplified and clarified, above).

Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions. This term
is most commonly used in a ruling that lists previously published rulings that are obsoleted because of changes in laws or
regulations. A ruling may also be obsoleted because the substance has been included in regulations subsequently adopted.

Revoked describes situations where the position in the previously published ruling is not correct and the correct position is being
stated in a new ruling.

Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published
ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same position published under
the 1939 Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations,
names, etc., that were previously published over a period of time in separate rulings. If the new ruling does more than restate
the substance of a prior ruling, a combination of terms is used. For example, modified and superseded describes a situation where the substance of a previously published ruling is being changed in part and is continued without
change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self
contained. In this case, the previously published ruling is first modified and then, as modified, is superseded.

Supplemented is used in situations in which a list, such as a list of the names of countries, is published in a ruling and that list is
expanded by adding further names in subsequent rulings. After the original ruling has been supplemented several times, a new
ruling may be published that includes the list in the original ruling and the additions, and supersedes all prior rulings
in the series.

Suspended is used in rare situations to show that the previous published rulings will not be applied pending some future action such
as the issuance of new or amended regulations, the outcome of cases in litigation, or the outcome of a Service study.

Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use
the following defined terms to describe the effect: